reforms are to be done, but who pays? -

reforms are to be done, but who pays? -

Illustration by Paola Parra

There is no doubt that the fiscal delegation was conceived and designed to please businesses: simplifications; bonus system for those who invest and hire; two-year arrangement with creditors and extension of cooperative compliance; alignment between statutory financial statements and fiscal discipline. And so on. But will all this, in the end, really lead to real simplification and a lower tax burden? And especially since when? At the moment, these questions have no definitive answer, even if the certainty of the law and the legitimate expectations of the taxpayer are the two most heralded cornerstones of the delegation. There are so many variables that they do not change the meaning of the expectations of the economic world. There is expectation, interest but, at the same time, also a little prudence mixed with some dose of skepticism given the problems with public finances. The opinion of the Bank of Italy on hedging was lapidary. As on the sustainability of the flat tax. Some ambitions seem excessive, if not foolhardy. Meanwhile, the times. The superficial impression that the reform, with such a solid majority, is certain and almost immediate.


You forget for that, once having obtained the green light from Parliament, the government will have 24 months at its disposal (there were 18 with the previous delegation approved only by the Chamber) to issue the delegate decrees. This means that, even if all goes well, the reform will not see the light before 2026. Almost at the end of the term. A geological era. Even if some aspect, for example relating to the proceedings, the third part of the delegation, could be suitably anticipated. The entrepreneurs' dilemma can also be declined as follows: should we believe - this time, even more than in previous attempts - in the promise to seriously tackle the tax system? Feelings are of various nature. And they surfaced in particular in the hearing, last Thursday, in the Finance Commission of the Chamber, of Assonime, the Association of Italian joint-stock companies, of which Patrizia Grieco is president and Stefano Firpo general manager.

Industry 4.0

What are the most important and delicate points for entrepreneurial activity at any level? Article 6 of the delegation provides - and perhaps the most relevant change - the reduction of the tax rate (perhaps up to 15 percent) for those who invest in industry 4.0, research and development or who hire in the two years following the generation of income. Reduction that does not apply to income corresponding to profits distributed during the period. If you set them aside you will get the discount, otherwise not. The tax administration will have to verify compliance with the conditions. Will it be able to do that too in a delegation that features the novelty of collaborative fulfillment and a myriad of new interlocutions?

The budget law

The 2023 Budget law authorized 4,000 hires in the financial administration. But there is the stumbling block of dedicated training. The old school named after Ezio Vanoni is gone. So how to evaluate private investments by public offices that are very different in terms of typology and implementation times? If they turn out to be superior, can they be discharged in the next two years? And, if less, will they result in a proportionately less benefit? Only these passages give the measure of the complexity in applying an important incentive, considered decisive for promoting growth. Companies also need above all adequate professionalism. The number of hires does not count. And if they favored the latter quantitative aspect they would certainly not go in the desired direction of an increase in productivity.


The risk of long and complex disputes should not be underestimated. The discount on IRES must then be harmonized with the discipline of global minimum tax which will enter into force from 1 January 2024, for which the Ace is questioned, i.e. the deduction to favor the capitalization of companies, and in general the whole system of reductions that act on the tax base, patent box included. How will the rate decrease coordinate with the business incentives awarded through tax credits. The Deputy Minister of the Economy, Maurizio Leo, ensures that a review of the 227 types of tax credits is underway that Cuban (horrendous verb but tax matters not from Branca) 36 billion.

The node on incentives and the EU

The most intricate node concerns the concept of novelty applied to incentives for research, development and innovation. Too loose. A requirement in many cases contested a posteriori by the Revenue and Collection Agency and the Guardia di Finanza with problems of compensation and after-effects also of a criminal nature. It should be up to the certifiers to ascertain the novelty requirement. It is a pity that there is not even a register of certifiers (Leo has been requesting it for some time). Moral: much of what concerns companies depends more on Community and international legislation (Pillar 2) than on the fate of the delegation. But in the public debate this does not emerge. And perhaps it would be appropriate for there to be greater government sincerity on this point. The goal of coming to a new tax control frameworkcommendable but certainly requires a different collaborative culture between tax authorities and companies, and an acrobatic, for now, cultural and professional leap. Suffice it, for example, to think of the flood of interpellations (17,000 in one year) that the government would like to overcome by returning to the use of circulars.

Regional and corporate income taxes

One of the by now historic battles of the entrepreneurs had Irap as its objective, the overcoming of which is foreseen by the delegation. But with what consequences on the possible IRES surcharge? The current revenue from Irap is 15 billion, 41 per cent of that from Ires. The risk that the surcharge (which would bring Ires to 32%) completely nullifies the benefit. By the way today it happens that those who lose IRES are still called to pay Irap, excluding the tax for personal companies which in fact have multiplied.

The covers

Once Irap is abolished, however, who will pay the cost of Healthcare, given that the regional surtaxes, while not questioned, are not enough? Also the so-called flat tax incremental raises some well-founded doubts. And not only for a general reason related to horizontal equity, but also for how productivity bonuses and fringe benefits should be treated. Businesses are pushing for some items such as training aimed at mobility and part of decentralized bargaining to be deductible. Here too, the issues related to the overall revenue equality of the entire reform do not escape, especially taking into account that the reduction of personal income tax rates will have to be financed, not to mention a further, albeit increasingly remote, expansion of the flat tax. Other more technical steps of the delegation are no less important. As the need to standardize the deductibility of all or part of interest expense and how to regulate business losses by the consolidating company. The famous tax coffins which, ironically, have been sought by companies as precious and miraculous gems in a legislative jungle in which the tax authorities have sometimes been not only a friend but even an accomplice.

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